Ekara Health Ltd
Complaints Policy & Procedure

This document sets out the firms Complaints Procedure which comply with the FCA Sourcebook DISP.
 As a firm we are committed to treating our customers fairly and we will seek to respond to all
complaints received promptly and fairly.

In order to ensure that complaints are fairly, consistently and promptly dealt with, the Chief Executive
must be consulted in all cases, and any proposed course of action or correspondence signed off by
the Director. The Director will be responsible for ensuring that any complaint is properly investigated
and is done so competently, diligently and impartially and that the required timetable set by the FCA
rules is adhered to.

In the event that a complaint identifies a systemic, recurring or specific problem, the Director will
seek to resolve it via discussion and the implementation of any conclusions arrived at.

1.1 Investigating, assessing and resolving complaints
Our obligations under DISP are that, upon receipt of a complaint, we must:

Investigate the complaint competently, diligently and impartially, obtaining additional 
information as necessary:

Assess fairly, consistently and promptly taking into account all relevant factors:

  • The subject matter of the complaint;
  • Whether the complaint should be upheld;
  • What remedial action or redress (or both) may be appropriate;
  • If appropriate, whether we have reasonable grounds to be satisfied that another
respondent may be solely or jointly responsible for the matter alleged in the 

Offer redress or remedial action when we decide this is appropriate;

Explain to the complainant promptly and, in a way that is fair, clear and not misleading, our
 assessment of the complaint, our decision on it, and any offer of remedial action or redress; 

Comply promptly with any offer ofremedial action or redress accepted by the complainant.

1.2 Time barred complaints
If we receive a complaint which is outside the time limits for referral to the Financial Ombudsman
 Service we may reject the complaint without considering the merits of the complaint. If we chose to
so reject a complaint, we must explain this to the complainant in a final response letter.

2.1 Identify the complaint

A complaint will involve an allegation from a customer or potential customer that they have suffered 
financial loss, distress or material inconvenience in the company’s provision or failure to provide a
financial service.

If the recipient of the complaint isunsure regarding the complaint please refer it to the Director.

In the event that a customer wishes to make a complaint, this can be made verbally, by telephone or
in person, or via a written communication delivered in person, via post, e‐mail, sms or fax. In the first 
instance, the complaint should be handled by the manager responsible for the account, in
consultation with the Chief Executive, and resolution of the complaint sought.

2.2 Complaints resolved within 3 business days
We will seek to resolve any complaints received as quickly as possible with a view to reaching 
agreement with the complainant within 3 business days of receipt. In the case of resolved complaints
note will be made in the customers file of any agreed course of action together with any copy
correspondence. We will then promptly send the complainant a summary resolution communication
 which includes the following detail:

  • Refers to the fact that the complainant has made a complaint and informs the complainant
 that we now considers the complaint to have been resolved;
  • Informs the complainant that if he subsequently decides that he is dissatisfied with the
resolution of the complaint he may be able to refer the complaint to the Financial 
Ombudsman Service but must do so within 6 months as otherwise the Ombudsman will not
have our permission to consider the complaint and so will only be able to do so in very limited
  • Provides the website address of the Financial Ombudsman Service and refers to the
 availability of further information on the website of the Financial Ombudsman Service.

2.3 Process for complainta not resolved within 3 business days
In the event that a complaint is not capable of resolution by the close of business on the third business
day following the day on which it was received then a brief written explanation of the substance of
the complaint should be provided together with any written correspondence from the customer
 concerned. At this point in time, an entry should be made in the Complaints Register and the date of receipt of the complaint recorded in the Complaints Log, an example of the format of which
appears in Appendix A.
If the complaint has not been resolved by the close of business on the second day, we must ensure
that a copy of these internal procedures are sent to the customer and receipt of the complaint
 acknowledged in writing within 5 business days. The name and job title of the person handling the
 complaint must be advised to the customer.

2.3.1 Investigation of the complaint

Investigation must be done by either the Chief Executive or a Director of the company.

We must investigate a complaint and ensure we understand fully the complaint that has been made.
 We need to have good communication with the complainant.

2.3.2 After 4 weeks
If a complaint has not been resolved within 4 weeks of being received, unless the customer has
already indicated in writing acceptance of a response by the company (provided that the response 
informed the customer how to pursue his complaint if he remained dissatisfied), and in the event
that a final response has not been issued, a holdingresponse must be sent to the customer explaining
 why the company is not yet in a position to resolve the complaint and indicating when the company
 will make further contact (which must be within 8 weeks of receipt of the complaint).

2.3.3 Final response
A Final Response must be made within 8 weeks of receiving the complaint.

This response sets out the final view of the company on the complaint, dealing directly with the issues 
the customer has raised.
It will summarise the complaint and summarise the outcome of the investigation.

The written final response must either:

  • Accept the complaint and offer appropriate redress. We must include a clear explanation of
 how we have arrived at this offer.
  • Reject the complaint giving the reasons behind this decision.
  • A combination of a) and b)

We must inform the customer that they have 8 weeks to respond to our final response until we
 consider the complaint closed.
Response must include:

  • “If you remain dissatisfied with this response you are entitled to take your dispute to the
 Financial Ombudsman Service within 6 months of receiving this letter.”

And must include:

  • The Financial Ombudsman Service Leaflet.

A complaint will be deemed to be closed where the company has sent a final response or where the
 customer has indicated in writing acceptance of the company’s earlier response.

2.4 Resolution

Where a complaint has been resolved, a final response should be issued to the customer, unless it
 was resolved by the close of business on the business day following receipt, in which case no letter
need be sent. A final response is a written response from the company which accepts the complaint
 and, if appropriate, offers redress (appropriate redress may not involve financial redress, it may, for
example, simply involve an apology); or offers redress without accepting the complaint or rejects the 
complaint and gives reasons for doing so, and which informs the customer that, if he remains 
dissatisfied with the company’s response, he may now refer his complaint to the Financial
 Ombudsman Service (“FOS”) which, should he wish to do so, must be done within 6 months.

2.5 Record keeping
A record of the complaint must be retained by the company for 3 years from the date of the receipt
 of the complaint. A report must be made to the FCA twice a year, as at 31 March and 30 September
via the FCA’s Firms on Line electronic reporting system. This report specifies the total number of
complaints received by the firm which were not settled by the close of business on the third business
 day after the receipt of the complaint in accordance with rule DISP 1.5.4.

2.6 Staff acknowledgment & responsibility
All staff are required to sign a copy of these internal complaints procedures to confirm that they have
received, read and agree to be bound by the requirements placed upon by them by these procedures
 as part of their contract of employment. Failure to comply with this policy may result in disciplinary